Hedge Capital | Privacy Policy

This Privacy Policy addresses natural persons and refers to how Hedge Capital LTD (“The Fund”) collects and processes your personal data and informs you of your rights in accordance with relevant national laws and the General Data Protection Regulation of the EU 2016 / 679 known as GDPR. This privacy policy will explain how the Fund uses the personal data we collect from you when you use www.hedge.capital (“the Website”) and our fund investment services (“the Services”). Your personal data includes information that may lead, either directly or in combination with others, to your identification as a natural person.

General principles

The Fund is bound, inter alia, by the following principles when processing personal data:

Lawfulness, fairness and transparency;
Purpose limitation;
Data minimisation;
Accuracy;
Storage limitation;
Integrity and confidentiality; and
Accountability.

Data Controller

The Fund is the data controller, i.e. the person who collects data and is responsible for them.

Contact information for purposes of data protection may be found on the Website.

Purposes of processing
The Fund processes personal information primarily for the following purposes:

For orderly provision of services to its clients;
To be compliant with legal obligations;
For performance of contracts;
To prevent money laundering and terrorist financing;
To run a functional and secure Website.

What are the legal ground for the collection?

Collection of personal data by the Fund is required particularly by relevant laws on investment companies and investment funds and its implementing acts, on measures to combat money laundering and terrorist financing, and public interest to prevent money laundering and terrorist financing. Consent is required to process personal data to run a functional and secure Website.

What data do we collect?

Personal identification information - as required by relevant KYC/AML regulations when you become a client of the Fund. We may collect, inter alia, your name, date of birth, personal ID or passport, address, phone, email, tax or corporate identification number, company legal status and company beneficial owners identification information.
Information from third parties - Information about you or your company representatives or beneficial owners from third party sources as permitted by applicable law, such as public databases, ID verification partners or sanction lists.
Automatically collected data - The Fund or its service providers may receive and store certain types of information automatically whenever you interact with the Website or use the Services. This information does not necessarily reveal your identity directly, but may include information about the specific devices you are using, such as the hardware model, operating system version, web-browser software, your Internet Protocol (IP) address/MAC address/device identifier, broad geographic location and other technical data collected through cookies, pixel tags, and other similar technologies that uniquely identify your browser.

How do we collect your data?
You directly provide the Fund with most of the data we collect. We collect data and process data further:

Directly during the process of contracting with the Fund for using the Services.
Indirectly during the processes of verification of submitted personal or company data at third party databases such as OFAC list, UN and EU sanction lists or identification document registers.
Directly or indirectly during your use or view of the Website via your web browser.

How will we use your data?

The Fund collects your data to be able:

To comply with a legal or regulatory obligations. Especially to verify your identity by comparing your personal information against third-party databases in order to stay compliant with relevant KYC/AML regulations during providing you the Services.
To prevent and investigate potentially prohibited or illegal activities, and/or violations of relevant laws and regulations as relevant to the Services.
To contact you with regards to any actions or duties as arising from contractual relationship of providing you the Services. Such as, to email you with the Fund regular investment updates or important notices or requests as the Fund management may require.
To provide you with information on a functional and secure Website. To customise, measure, and improve the Website. To enhance security, prevent fraud and to combat spam or other malware or security risks.
To enforce agreements with third parties as needed to maintain the Website or provide you the Services.

What happens when you reject to provide us your data?

With regards to data collected for contracting purposes: The Fund is not allowed to contract with a person who rejects to provide its personal data in the range set by applicable laws. If you reject to provide such data, the Fund must not enter in agreement with you and/or the Fund has to terminate an existing agreement with you.

With regards to data collected during your use or view of the Website via your web browser: If you reject to provide your data, the Website will continue to work. However, your experience from the Website and its functions may be worsened.

How do we store your data and for how long?

The Fund maintains (and requires its service providers to maintain) appropriate physical, technical, and administrative safeguards to protect the security and confidentiality of your personal information. The Fund may store and process all or part of your personal and transactional information elsewhere in the world, where the Fund service providers are located. The Fund protects your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations. The Fund will keep your data for not longer than mandated by relevant laws or regulations or than necessary. Once this time period has expired, we will delete or discard your data.

Marketing

The Fund will not use your personal data for marketing purposes.

Can data be provided to third parties?
To comply with applicable laws, the Fund may make your data available to persons and bodies who are obliged or entitled to be provided such data. This concerns primarily state bodies or auditors.

Will my data be transferred to third countries?

The Fund does not plan to transfer your data to countries outside the European Union. In case a transfer of data to a third country, where the level of protection of personal data is not regarded as adequate by the European Union, takes place, the Fund shall use binding corporate rules approved by the European Commission and follow the rules set out in GDPR.

What are your data protection rights?
The Fund would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request the Fund for copies of your personal data.
The right to rectification – You have the right to request that the Fund corrects any information you believe is inaccurate. You also have the right to request the Fund to complete the information you believe is incomplete.
The right to erasure – You have the right to request that the Fund erases your personal data, under certain conditions.
The right to restrict processing – You have the right to request that the Fund restricts the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to the Fund’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that the Fund transfers the data that were collected to another organization, or directly to you, under certain conditions.
The right to lodge a complaint - You have the right to complain about the Fund’s processing of your personal data to a competent supervisory authority as long as you deem the processing in contravention of GDPR. The competent supervisory authority in the Czech Republic is Úřad pro ochranu osobních údajů, residing at Pplk. Sochora 27, 170 00 Praha 7, www.uoou.cz.

If you make a request, we have 1 month to respond to you. If you would like to exercise any of these rights, please contact us at our email: info@hedge.capital.

Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the Website, we may collect information from you automatically through cookies or similar technology.

How do we use cookies

The Website by default uses cookies in a range of ways to improve your experience on the Website and associated online services connected to the Website in order to understand how you use our website, which content parts you find useful, to ensure our Website is secure and safe to use.

What types of cookies do we use?

There are a number of different types of cookies, however, our website may use:

First-party cookies: Cookies necessary for proper functioning of the Website.
- Strictly necessary: Session cookies enabling browsing and website security (type of device to optimise Website viewing, identifies logged-in users if applicable, security).
- Functional: Cookies that "remember" visitors in order to improve user experience (unique visitors identification, Website session activity and rendering).
Third-party cookies: Cookies that are placed and used by third parties.
- Functional: Session security cookies.

Session (transient) cookies: These cookies are erased when the Website visitors close their browsers and are not used to collect information from their computers. They typically store information in the form of a session identification that does not personally identify the user.

Persistent (permanent or stored) cookies: These cookies are stored on the visitor's hard drive until they expire (at a set expiration date) or until they are deleted. These cookies are used to collect identifying information about the user, such as web surfing behaviour or user preferences for a specific site.

How to manage cookies
You can set your browser to not accept cookies. However, in a few cases, some of our Website features may not function as a result. Please refer to specific steps of managing cookies in your browser via links below. If may find more on managing cookies at www.allaboutcookies.org.

Privacy policies of other websites

The Website contains links to other websites that may place cookies from third-party service providers, who may use information about your visits to other websites. The Fund or its Website does not control the types of information collected and stored by these third-party cookies. Our privacy policy applies only to our Website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

The Fund keeps its Privacy Policy under regular review and places any updates on this Website. The Fund reserves the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes.

How to contact us
If you have any questions about the Fund’s Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at info@hedge.capital.